First Aid Requirements

Are you meeting your legal and moral obligations to ensure your employees have access to prompt medical attention either by first aid or full medical treatment? The OSHA medical services and first aid requirements for general industry are covered in 29 CFR 1901.151. The standard states: “In the absence of an infirmary, clinic or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.”

The standard is somewhat ambiguous as it fails to define such words as “near proximity” or “adequately trained.” For example, under certain circumstances, the standard requires first aid training, but it does not specify what constitutes “adequate training.” Industry has asked OSHA for clarification of these words along with other requests for clarification of this standard. OSHA has responded to these requests with several letters of interpretations that should help us better understand what is required.

The size of the company or the type of work performed by its employees has no bearing on the applicability of this standard. There are no exemptions for first aid protection due to a company’s size, and all industries are required to comply with the standard regardless of the type of work performed by employees. However, the hazards and related first aid/medical services required would be less for an office, for example, than they would be for a cylinder fill plant.

Your first aid program must correspond to the hazards that can be reasonably expected to occur in the workplace. You must evaluate the potential work-related hazards and provide for first aid accordingly. In making these determinations, you should consider the work process that could cause illness or injury to employees; the type of accidents that have occurred in the past, as well as those likely to be encountered in the future; and whether employees are exposed to falls, hazardous machinery or harmful chemicals.

When first aid treatment or professional medical care cannot be administered to injured employees by outside professionals within a three- to four-minute response time for serious accidents resulting in such things as suffocation, severe bleeding, or other life-threatening or permanently disabling injury or illness, a person or persons within the facility must be adequately trained to render first aid. In other circumstances, such as in an office environment where employees perform administrative duties and where a life-threatening or permanently disabling injury is an unlikely outcome of an accident, a longer response time, such as 15 minutes, is acceptable.

OSHA does not teach first aid courses or certify first aid training courses for instructors or trainees. First aid courses need to be individualized to meet the needs of the workplace, and it is the responsibility of the employer to coordinate this effort with the organization that will be conducting the training. The American Heart Association, the American Red Cross, the National Safety Council and other nationally recognized and private educational organizations offer first aid training.

Appendix A to §1910.151 First Aid Kits (Non-Mandatory) refers to ANSI Z308.1-1998 “Minimum Requirements for Workplace First Aid Kits.” This ANSI standard was updated in 2003, but as yet is not referenced in Appendix A. The 2003 ANSI standard provides detailed information regarding the requirements and recommendations for first aid kits. Complying with this latest ANSI update should meet the requirements of providing adequate first aid supplies. OSHA often refers employers to ANSI Z308.1 as a source of guidance for the minimum requirements for first aid kits. The ANSI Z308.1-2003 “Minimum Requirements for Workplace First Aid Kits,” along with other relevant information, is available on the GAWDA OSHA & EPA consultant Web page at www.gawda.org.

ANSI Z308.1-2003 Minimum Requirements for Workplace First Aid Kits

These items were specifically spelled out in the 1998 update.

Quantity Description
1 Absorbent Compress, 32 sq. in. with no side smaller than 4 in.
16 Adhesive Bandages, 1 in. x 3 in.
1 Adhesive Tape, 5 yd.
10 Antiseptic, 0.5 g (0.14 fl. oz.) application
6 Burn Treatment, 0.5 g (.014 fl. oz.) application
4 Medical Exam Gloves
4 Sterile Pad, 3 in. x 3 in.
1 Triangular Bandage, 40 in. x 40 in. x 56 in.


Recommended Kit Contents

(These items are not necessary, but should be considered.)

These were added as recommendations in the update in 2003.

Quantity Description
16 Analgesic/Pain Reliever (i.e., Tylenol, aspirin)
6 Antibiotic Treatment, 1/32 oz.
4 Bandage Compress, 2 in. x 36 in.
2 Bandage Compress, 3 in. x 36 in.
1 Bandage Compress , 4 in. x 36 in.
1 Breathing Barrier
1 Burn Dressing, 4 in. x 4 in.
1 Cold Pack
2 Eye Covering, 2.9 sq. in. per eye
1 Eye Wash, 1 oz.
1 Roller Bandage, 4 in. x 6 yd.
2 Roller Bandage, 2 in. x 6 yd.
  1. Kits should be adjusted to included items based on the specific hazards existing in a particular work environment.
  2. Kits should contain a single-use, disposable CPR barrier.
  3. Kits should be inspected regularly to ensure completeness.
  4. Periodic inspection of the “assortment” should be performed for possible updating.
  5. Tourniquets are not included in the minimum fill requirement and should be used only as a last resort.
  6. Over-the-counter drug products should be in a single-dose, tamper-evident package.
  7. Over-the-counter drug products should not include ingredients that are known to cause drowsiness.
  8. All first aid kits meeting the “Minimum Requirements of Basic Fill Contents” should be marked with ANSI Z308.1-2003 designation.
  9. Each complete first aid kit meeting the requirements of ANSI Z308.1-2003 should have a label on the back or outside of the kit listing the minimum items and quantity that must be maintained in the kit.
Gases and Welding Distributors Association
Meet the Author

GAWDA OSHA & EPA Consultant Thomas W. Eynon is senior associate at B&R Compliance Associates LLC, based in Merritt, North Carolina. Members can reach him at (252) 745-7391 and at tom.eynon@brcompliance.com.